Chaney v. United States, No. 17-2024 (6th Cir. 2019)
Annotate this CaseChaney pleaded guilty to possession of a firearm and possession with intent to distribute cocaine. Because his criminal history included convictions for one “serious drug offense” and two “violent felon[ies],” Chaney was sentenced as an armed career criminal, subject to the Armed Career Criminal Act’s 15-year mandatory minimum, 18 U.S.C. 924(e)(1). On collateral review, Chaney argued that one of his three predicate convictions (a 1981 Michigan conviction for attempted unarmed robbery) did not qualify as a “violent felony” after the Supreme Court’s 2015 invalidation of the ACCA’s residual clause (Johnson). The Sixth Circuit rejected his argument, finding that Chaney’s conviction qualifies as an ACCA-enhancing violent felony under the elements clause, which continues to apply notwithstanding Johnson. Michigan unarmed robbery (as it existed in 1981) counts as a violent felony under the ACCA’s elements clause even though the statute extends to “putting [a victim] in fear,” because under Michigan law “putting in fear” means “putting in fear of bodily injury from physical force.”
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